Scottish Land & Estates, which represents 2,500 landowners across Scotland, described the release of the European Commission’s extensively leaked Common Agriculture Policy Reform proposals as a “mixed bag”.

Luke Borwick, Scottish Land & Estates Chairman said: “There are some positives for Scottish agriculture in these proposals and some negatives. The key in making sure this reform works for Scotland will lie in the next phase of negotiation and ensuring that the negatives are removed before the regulations are finally agreed.

“Despite all the calls for greater simplicity, the Commission has brought forward a set of proposals that will result in a more complex system of direct payments. Yet this complexity may well work in Scotland’s favour. Having a range of tools available – such as a basic payment scheme, coupled support, a small farmers’ scheme and payments for areas of natural handicap – potentially allows us to tailor support to the diversity of Scottish agriculture.

“Moving from the historic approach to Single Farm Payment towards an area-based scheme was always going to present Scotland with a major problem, but under the draft proposals we potentially have a range of tools that we can utilise to take some of the sting out of that process. It will be vital to ensure, however, that the tools are designed properly and implemented sensibly.

On capping

David Seed, Chair of Scottish Land & Estates’ Primary Industry Policy Group said:

“We would like to see the Scottish and UK Governments fighting hard to have the capping provisions removed. On the one hand, the European Commission encourages structural change to achieve greater efficiency and competitiveness, but on the other, their capping proposals threaten to discourage or reverse that structural change.

On active farmers

“It is entirely right that we seek to ensure that agricultural support goes to active farmers and not to non-agricultural businesses. However, we also need to make sure that the measures we put in place are proportionate and not overly bureaucratic. We will therefore argue strongly against definitions of active farmers that will be a nightmare to enforce. We need to avoid the situation where support is diverted to administering a bureaucratic paper chase”.

On eligible hectares

“The proposal that entitlements under the new regime should be linked to beneficiaries of the direct payments system in 2011 will clearly discriminate against active farmers that are not current recipients of support or new entrants going into farming after 2011. Scottish Land & Estates will fight to see these provisions removed. The CAP should be designed to deliver certain outcomes and not get into the business of determining who delivers the outcomes”.

On greening

We have long argued that we need to develop a more robustly justifiable CAP regime and that we should achieve this by putting greater emphasis on the delivery of public goods. The proposals to ‘green’ direct payments therefore potentially move us in the right direction. But it will be vitally important to strike the right balance. We need greening measures that are practical at farm level and which meaningfully deliver additional environmental benefit. Some of the proposed greening measures look like they would interfere in farming operations for many farms without obvious environmental gain.

On convergence

“Given the asymmetry in payments rates per hectare across Scotland, the obligation to move to a uniform payment rate at the regional level by 2019 potentially leads to massive change for some. We cannot avoid significant change and we should recognise that, but the key will lie in determining regions within Scotland and this will be for Scotland to decide. The idea of complete convergence with flat rate support across the EU would, however, be a step too far”.

On rural development funding

“It is far from clear that the abysmally low Scottish share of Pillar 2 funds will be rectified. Scottish Land & Estates wants to see the Scottish Government fighting for an enhanced Pillar 2 budget and for some form of transitional arrangement that would avoid a hiatus in support should the current reform be delayed”.